Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on record by the Revenue to suggest that the transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis
Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on record by the Revenue to suggest that the transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis
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